Commission de sécurité des consommateurs

 

 

HAVING REGARD TO the Consumer Code and specifically Articles L. 224-1, L. 224-4, R. 224 4 and R. 224-7 to R. 224-12

HAVING REGARD TO petition no. 04-131

 

In 2004, seven petitions on the failure of electronic driving assistance systems installed on cars were filed with the Consumer Safety Commission. At that time, articles in the trade press were also addressing issues generally related to on-board computer systems.

Given that such systems were being widely installed on new cars, the Commission decided, during its 4 November 2004 session, to initiate the procedure for a draft recommendation on the safety of electronic driving assistance systems.

 

 None of the current systems for collecting statistical data on road accidents allow an accurate assessment of the impact of electronic driving assistance systems on road safety to be made. For France, the Observatoire national interministériel de sécurité routière (National Interministerial Road Safety Observatory) (ONISR), which was heard by the Commission, is not able to determine the number of accidents that can be directly attributed to electronic driving assistance systems, and even less able to determine those accidents that were directly avoided thanks to such systems, because the variable is not a separate item in the road accidents statistics. Consequently, figures published in reports, recommendations or official studies on the subject stem from a general analysis of the accident causes in the entire fleet of vehicles (whether fitted with such systems or not) or from crash tests conducted in the lab.

 

For Europe, feedback is available only for GPS, which spread rapidly thanks to roaming systems. According to a study conducted by the Netherlands Organisation for Applied Scientific Research (TNO), owners of cars fitted with a global positioning system file fewer damage claims with their insurers due to lower mileage (-16%) and shorter driving time (-18%).

 

The studies concur, however, that the widespread installation and proper use of electronic driving assistance systems in all vehicles would prevent collisions in 40% to 65% of cases, lower impact speed by 15% in one-third of cases, and avoid loss of vehicle control in 30% of cases, which would be incontrovertible progress for road safety. 

 

 

Currently, electronic driving assistance systems represent only a small share of on-board automotive electronics. The introduction of this type of electronic system is the greatest technological revolution in the automobile industry of the past twenty years. Despite the lower cost of electronic components, the value of the electronic content of a car has increased tenfold in twenty years and the value is expected to reach more than 50% of car cost in 2010. Today 80% of the innovation in the automotive industry is directly linked to electronics.

 

Initially, on-board electronics were dedicated to engine management (including diesel injection pumps and engine cooling systems), then to the improvement of driver comfort and safety (such as an electronic ignition key, automatic seat settings, airbags, seat belt pretensioners, etc.), before gradually spreading to driver-car interfaces with electronic driving assistance systems.

 

This type of equipment is usually broken down into two categories:

 

−         'Passive’ systems (In-Vehicle Information System or IVIS) that inform drivers of the condition of their vehicles (on-board computer, tyre pressure gauge), provide information on their immediate and distant surroundings (parking guidance system, lane departure warning, navigation assistance), and facilitate driver's environmental perception (blind spot detection, head-up display, night vision assistance)

 

−         ‘Active’ systems (Advanced Driver Assistance Systems or ADAS) that act on car dynamics or activate certain functions. They may be triggered automatically when a critical situation occurs (anti-lock braking system or ABS, emergency braking assistance system or electronic stability programme), or may be activated by the driver in order to lighten the driving load (activation of windscreen wipers, headlights, or cruise control)

 

The penetration rate of electronic equipment in vehicles depends on the systems, automakers, and vehicle models. In October 2006, all vehicle categories taken together, the penetration rate of four major driving assistance systems in new cars was as follows:

 

ABS	ESP	Cruise Control	Emergency braking assistance system
100%	59%	69%	41%

 

 

Four developments will further modify the place of on-board electronics in cars in the short to medium term, including:

 −         The interconnection of various types of equipment enabling the car to communicate with the outside environment, such as the integration of a cell phone, on-board navigator and computer. Such a system could, for example, receive information on road conditions and the weather, send an emergency warning in case of accident (European eCall project) and perform remote diagnosis of breakdowns via the automaker’s repair network.

−         The introduction of equipment that interacts with the environment in real time, such as intelligent speed adaptation based on traffic signs (LAVIA project) or car spacing control

−        Car control will be taken over automatically in certain circumstances (car breathalyzer with ignition interlock device, automatic braking) or upon driver request during complicated manoeuvres (automatic car parking system)

 −         The use of voice commands to programme some equipment (GPS, for instance).

 

In international automotive regulations, only ABS is mandatory.

In France, Articles 317-6 and 317-6-1 of the Highway Code make it mandatory for public transport vehicles and vehicles whose total authorised load weight exceeds 3.5 tons to be fitted with speed-limit devices and tachographs.

The above systems must also undergo all the automotive subassembly and component approval procedures for EU whole vehicle type approval.

Directive 1400/2002 of 31 July 2002 authorises the access of all repair and emergency road service professionals to information and technical training.

Among the numerous standards in effect in the automotive industry, the following standards specifically apply:

 - Standards ISO TC22 and TC 204 on adaptive cruise control, parking guidance systems or driver hypoviligance detection

- Standard ISO 2575:2006 – Road Vehicles – Symbols for controls, indicators, and telltales, establishing new symbols

- Since 2005, Standard EOBD on engine management for all cars. It promotes the development of on-board diagnostics for every car make and is updated regularly.

  

In terms of safety, the introduction of a new technology onto a market such as the automotive market (thirty million passenger cars in France and two million new vehicles sold every year) is a major technical and human challenge. Successfully meeting the challenge depends as much on the technical reliability of the marketed products as it does on drivers’ ability to use the systems properly. Therefore, the Commission’s inquiries focussed on both aspects.

 
- Technical Failures

Applying electronics to automotive construction is tricky due to the constraints that the systems are subject to in a vehicle (vibrations, shocks, heat, humidity, electromagnetic disturbances), constraints which are harder to control than in aeronautics. A very sophisticated technical solution may be the cause of a failure.

However, major advances have been made over the past three years to make systems more reliable. Nevertheless, auto repair mechanics, and particularly independent professionals, still lack skills in this field as the access to information and training are still difficult and costly.

 

 CSC Inquiries:

From January to March 2007, an ergonomics study was entrusted to the Laboratoire National de Métrologie et d’Essais (LNE, National Testing Laboratory), assisted by Beltoise Evolution. A group of 24 drivers (licensed for more than two years) was selected. Half were proficient electronic driving assistance system users and half had never used such systems. The drivers were placed in a situation where they had to use five of the systems most commonly found on the market (onboard navigator, automatic parking brake, parking guidance system, the speed-limit device and cruise control). Each driver had to use two of the systems during a road test and under standard driving conditions. A series of questions, asked before and after the tests, served to assess user knowledge and record their remarks.

The final test report was then subject to the analysis of three researchers from the Laboratoire d’ergonomie et de sciences cognitives pour les transports (LESCOT, Ergonomics and Cognitive Sciences for Transport) at the Institut national de recherche sur les transports et leur sécurité (INRETS, the French National Institute For Transport and Safety Research), who have been working on electronic driving assistance systems for several years. Although the scientists pointed out the limits of their interpretation due to the size of the studied sample and to certain test methods, they confirmed the overall relevance of the conclusions of the study whose summary can be found in Appendix 2.

The reported facts are as follows:

The systems are well accepted by drivers but are perceived more as providing increased comfort and a means for not violating the Highway Code than as a safety support.

The knowledge of system handling is deficient. Among others, the drivers do not know that:

- ABS (anti-lock braking system) requires continuous pressure on the brake pedal despite the vibration caused by system switch-on

- The Electronic Stability Programme has to be disconnected on snowy or muddy roads

Other systems may induce stress, cause driver attention to flag or lead to driver overconfidence and thus risky behaviour.

  

 

Whereas the improvement of road safety implies both action concerning vehicles, roadways and driver behaviour;

 

Whereas electronic driving assistance systems, properly used by a growing number of drivers, may substantially improve road safety;

 

Whereas major progress, including improved standards, could still be made to increase operating and usage safety of the said systems;

 

Whereas the gap between the resources and skills of some auto repair professionals and the complexity of the new technologies installed on recently commissioned vehicles still endures;

 

Whereas driver behaviour is now the determining factor in the area of the safety of electronic driving assistance systems, the public authorities and relevant professionals must carry out priority improvement actions of the said behaviour;

 

Whereas the qualifying programmes and examinations of beginner and ongoing training courses for drivers does not include the acquisition of skills specific to the safe use of electronic driving assistance systems;

 

Whereas the information that automakers, dealers and car rental professionals provide to consumers when they purchase or hire a car is insufficient in view of the complicated use of some electronic driving assistance systems;

 

Whereas it is the driver’s responsibility, including in the case of used car sales between individuals, to find out about the driving assistance systems installed on the car and on their limitations, to check their ability to use said systems, and never to use them for another purpose.

 

After having heard a representative of the Laboratoire national de métrologie et d’essais and of Beltoise Evolution in session;

 

 

 

 

 

 

·         Set up the necessary statistical tools:

 

−         To measure the impact of electronic driving assistance systems on road safety

−         And, after an in-depth analysis of accident causes, to enable the ongoing improvement of the functional, technical and ergonomic design of electronic driving assistance systems by automaking professionals

 

·         Take legal measures making it mandatory to include, in theoretical and practical driver’s training, instruction on the use of so-called ‘active’ electronic driving assistance systems, specifically the ones involving vehicle speed and braking

 

·         Continue the development of road safety education during training courses for driver licence holders or point recovery courses or for the licence integrating good practices in so-called ‘active’ electronic driving assistance systems, specifically vehicle speed and braking systems

 

·         Complete the content of the mandatory periodical technical control of passenger cars with special tests of the performance and reliability of the so-called ‘active’ electronic driving assistance systems

  

 

·         Continue their standardisation work on electronic driving assistance systems by integrating performance and reliability requirements

 

·         Integrate in the upcoming amendments to Standard ISO 2575 on Road vehicles -- Symbols for controls, indicators and telltales specifications on sound, voice and touch controls and codes used for the interface between drivers and on-board electronic systems

  

 

·         Continue their efforts to improve the functional, technical and ergonomic design of electronic driving assistance systems

 

·         Take into account the complexity of electronic driving assistance systems and the difficulties in understanding their operations and using them properly and in a timely manner, during vehicle handover procedures

 

·         Improve the content and style of driver information on the implementation of the systems in traffic, their control, maintenance and limitations in the instructions, handbooks or multimedia aids supplied with the vehicle

 

·         Provide the car rental professionals whom they supply with the same training in vehicle handling procedures as the dealers in their sales network

 

·         Offer prices facilitating independent garage owners’ access to technical data and training courses

 

 4 – Car Rental Professionals

 

·         Inform future drivers systematically about the electronic driving assistance systems available on the vehicles they plan to acquire or hire

·         Use all available means to provide future drivers with practical assistance for using the systems when vehicle is delivered to driver

 

 5 – Insurance Companies, Road User Organisations and Driving Schools

 

·         Jointly with automotive professionals, implement informative and training actions for drivers so they use electronic driving assistance systems properly, with the priority objective of ensuring their safety and those of other people

 

 

·         Take into account the ergonomics and easy-to-use features of electronic driving assistance systems as criteria when purchasing a new or used car

 

·         Carefully read the instructions, pay attention to the multimedia aids about the cars or systems, and call on the sales network to understand the operating modes and learn the limitations of the electronic driving assistance systems

 

·         In all circumstances, comply with the said operating modes and one's own limitations while making sure they maintains a critical level of vigilance in order to be in control of the car at all times

 

·         After becoming proficient in the use of electronic driving assistance systems, driver must never use them for improper purposes

 

·         As needed, participate in the training actions offered by insurance companies, insurers and road safety authorities to assess and perfect their overall driving level and control in critical situations